No national DPP law — but EU exports require full compliance
Switzerland is not an EU member and is therefore not directly bound by ESPR (EU) 2024/1781. There is currently no standalone Swiss DPP obligation; Swiss authorities, standards bodies and industry associations are tracking the EU development through product safety, circular economy and export-promotion work.
For Swiss exporters, however, products in affected categories entering the EU market need a DPP regardless of where they are manufactured. The first hard deadline is 18 February 2027 for EV and LMT batteries as well as industrial batteries above 2 kWh. Further ESPR product groups will follow step by step through delegated acts in the 2025-2030 working plan. Without a DPP, companies risk market-access problems, product recalls and sanctions depending on the EU member state.
Competent authorities in Switzerland
- SECO (State Secretariat for Economic Affairs) — Primary federal authority monitoring ESPR/DPP developments for Switzerland; coordinates the Mutual Recognition Agreement (MRA) with the EU; produces regulatory impact assessments
- BAFU (Federal Office for the Environment) — Leads the national circular economy strategy and USG implementation (new Art. 35i/35j product requirements since 1 January 2025); no DPP mandate, but a relevant partner for LCA data and environmental criteria
- Switzerland Global Enterprise (S-GE) — Federal export promotion agency; informs Swiss exporters about DPP obligations via Swiss Business Hubs abroad; fee-based consulting available
- SNV (Swiss Association for Standardisation) — Full member of ISO and CEN; represents Swiss interests in international DPP standardisation processes; hosted a DPP information day on 10 November 2025
- GS1 Switzerland — Technical infrastructure enabler (GTIN, GS1 Digital Link, EPCIS, QR codes); ongoing pilot projects with Burckhardt Compression (compressor valves) and Swisspearl (façade panels)
Funding for Swiss companies
- Innosuisse — Innovation projects with implementation partners — 50–60% of research partner costs covered; project budgets typically CHF 130,000 to over CHF 500,000; circular economy and digitalisation explicitly eligible; 4 submission rounds per year
- Innosuisse — Start-up innovation projects — Up to CHF 500,000 non-repayable grant; Innosuisse covers up to 70% of eligible costs; annual budget ~CHF 160 million (2025–2028)
- Cantonal funding programmes — Hightech Zentrum Aargau (circular economy and energy efficiency for SMEs), Innovation Zurich / Ahead Zürich (start-ups and SMEs in sustainability and digitalisation); cantonal tax incentives via patent box and R&D deductions (effective corporate tax rates 11–21% depending on canton)
Since the EU Programmes Agreement was signed on 10 November 2025, Switzerland has again been associated to Horizon Europe, Euratom and Digital Europe retroactively from 1 January 2025. Innosuisse and cantonal programmes remain important for DPP-adjacent pilots; Horizon or Digital Europe projects follow the rules of the relevant calls.
Associations and industry context
- Swissmem (mechanical, electrical and metal industry) — ~1,100 companies; hosted an ESPR/DPP seminar (July 2024); emphasises that the EU as the primary export market makes ESPR directly relevant for Swiss MEM companies; warns against fragmented national approaches
- FH / Fondation de la Haute Horlogerie (watch industry) — ~500 member companies; DPP Masterclass I (2025) and DPP Masterclass II (5 February 2026, Geneva) in partnership with the Aura Blockchain Consortium and Deloitte — watch DPP as authenticity certificate and secondary-market enabler
- Swiss Textiles — "Sustainable Textiles Switzerland 2030" (STS 2030) programme jointly with SECO and BAFU; textiles are a prioritised product group in the ESPR Working Plan 2025-2030, with concrete DPP obligations to follow through later delegated acts
A notable feature of the watch industry: ~95% of Swiss watch production is exported, with the EU as a primary market. The Aura Blockchain Consortium (LVMH, Cartier/Richemont, Prada) has already digitally registered millions of luxury products — the DPP functions here simultaneously as authenticity certificate, grey-market protection and storytelling tool.
DPP by industry sector
DPP requirements differ significantly by product category. Most relevant for Swiss companies — strong in chemicals/pharma, watches and precision machinery:
- Chemicals & REACH — SVHC declaration, Safe & Sustainable by Design — Novartis, Roche, Lonza and Swiss pharmaceutical chemistry manufacturers affected, including for CH exports into the EU Single Market
- Batteries & Accumulators — Battery passport from 18 February 2027 — mandatory for Swiss battery manufacturers (Leclanché, Bühler) and importers of EV batteries into the EU
- Electronics & Electrical Equipment — RoHS/WEEE and future ESPR repairability and recycling requirements — Swiss precision electronics and watchmaking industry affected for EU exports
- Automotive & Mobility — EV battery passport 2027 — Swiss suppliers (ABB, Kistler, Endress+Hauser) to EU OEMs directly affected
- All ESPR sectors → — Sector-specific deadlines, data requirements and associations at a glance
Frequently asked questions by Swiss companies
Must a Swiss company that only sells within Switzerland implement the DPP?
No. Since Switzerland has no national DPP law, there is no DPP obligation for purely domestic sales. However, as soon as products are placed on the EU market — including through distributors — EU ESPR requirements apply in full.
What happens if no EU authorised representative is appointed?
Without an EU-based economic operator (authorised representative or importer), the product cannot legally be placed on the EU market. From 2027, many EU importers will refuse Swiss suppliers without a DPP to avoid their own liability risks.
Does the MRA (Mutual Recognition Agreement) play a role?
The MRA facilitates conformity assessment for certain product sectors, but it contains no ecodesign or DPP provisions. Swiss exporters therefore need to check separately which manufacturer, importer or authorised representative provides the DPP for affected EU product groups.
